Process Safety Management Valerie Orr Shazad Barghi Ralph Buchal Prepared for MINERVA November 2013 Introduction Module Outline What is PSM? Importance of PSM PSM Systems Rules, Regulations, and Guideline for PSM in Canada References and further reading 2 MODULE OUTLINE: PROCESS SAFETY MANAGEMENT Description: This module is meant to provide an introduction to process safety management (PSM). In a very simple sense, PSM is a framework for identifying and managing process risks. It is a type of safety management system that is specific for the process industries. Therefore, the principles are relevant to all disciplines of engineering involved in a process facility and are also broadly applicable to other manufacturing industries. The ultimate goal of PSM is to prevent the occurrence of major hazard incidents which are not appropriately addressed through traditional occupational health and safety procedures. This is due to the fact that many serious unplanned incidents are many times not simply attributable to any individual operator error. PSM strives to ensure all hazards of a process are identified and effectively managed for the lifetime of the process, regardless of changes in personnel, organization, or environment. The principles of PSM as taught in this module are based on a particular reference from the American Institute of Chemical Engineers Center for Chemical Process Safety (AIChE CCPS). 3 Primary Reading Materials: RISK BASED PROCESS SAFETY MANAGEMENT (2007) Introduction to the twenty elements of PSM developed by the American Institute of Chemical Engineers Center for Chemical Process Safety SAFETY MANAGEMENT: A COMPREHENSIVE APPROACH TO DEVELOPING A SUSTAINABLE SYSTEM (2012) A comprehensive look at the factors that affect safety improvements and the effectiveness of a process safety management system. Large focus on the human factors which affect the adoptions of safe work practices, such as leadership and behavior. 4 Chapter Title 1 Introduction Contents The importance of PSM in the prevention of major hazard incidents Brief History and recent examples Rules and Regulations for PSM in Canada PSM Systems Elements of Process Safety Management 2 Commitment to PSM 3 Hazard Identification and Risk Assessment 4 Risk Management 5 Enhancing PSM 1. 2. 3. 4. 5. 6. 7. Process safety culture Compliance Competence Workforce involvement Stakeholder outreach Hazard identification & risk management Knowledge management 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. Operating procedures Training & performance Safe work practices Asset integrity & reliability Contractor management Management of change Operational readiness Conduct of operations Emergency preparedness Incident investigation Auditing Metrics & measurements Management review 5 PSM is the proactive application of management principles to a process for the prevention of loss of containment events PSM is a system for dealing with: What is Process Safety Management (PSM)? “… human performance in complicated systems that involve inherent risk” – Aviation Safety Expert and Pilot Chelsey Sullenberger (Interview on the application of aviation systems safety lessons to medicine CBC Radio 2013) This applies to the process industries too Any site which stores, handles or manufactures hazardous substances or energy will have an inherent risk Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 6 A loss of containment incident (LoC) occurs when a harmful substance or energy is released outside of the equipment which is meant to contain it [1,2,3,4] Loss of Containment In some countries the amount of substance released dictates whether the incident is reportable to the government Also, in some countries, the amount of hazardous material contained in either equipment or at a facility can determine if implementation of PSM systems is required; e.g., Environment Canada Environmental Regulations, US OSHA PSM Rule 1910.119 [3, 5] 7 Faulty gauge causes an overfill of a storage tank spilling 10000 kg of ethanol 2000 kg of crude oil leaks from corroded piping Examples of PSM incidents Introduction Operator opens process valve and causes acid spill and gets burned Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 8 PSM systems are meant for industries handling, storing, or manufacturing hazardous substances Intent of PSM Hazardous substances are defined by their reactivity, toxicity, flammability, or other dangerous properties by the Canadian Environmental Protection Act Part 8 Section 200 [5] PSM is primarily intended for the process industries and is typically applied at a facility level Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 9 PROACTIVE PSM is a Proactive Risk Based Approach REACTIVE • Implementing countermeasures to prevent an incident • Implementing countermeasures after an incident has occurred • Perform hazard analysis and risk assessment • Perform incident investigation and determine root cause • Practice inherently safer design • Design & install additional layers of protection after an incident [1] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 10 PSM is a subset of system safety Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 11 OCCUPATIONAL HEALTH & SAFETY PROCESS SAFETY Individual-oriented & controlled Focused on direct interaction between individual and equipment or structures Specific impact Work place rules & safety equipment Worker training & supervision Examples of Possible Incidents Examples of Possible Incidents • • • • • • • • • • Fall Spill Electrocution Asphyxiation Hearing Impairment and other chronic injuries Minor injuries (pinch, banged knee, etc.) Examples of Safeguards • • • • Hazardous Work Permits Personal Protective Equipment Ventilation systems, confined space entry Guardrails, equipment guards Introduction Commitment to PSM [5,6, 7] Cooperative Broad impact Systems Little individual control Explosion Release of hazardous chemical Fire Release of hazardous energy Examples of Safeguards DESIGN OPERATIONS • • • • Pressure Safety Valves Inherently Safer Design Equipment Interlocks Process Alarms Hazard & Risk Assessment Risk Management • • • • Maintenance Inspections Training Procedures Enhancing PSM 12 PSM is important because loss of containment events in the process industries can have DIRE consequences for employees, the public, and the company. Why is PSM Important? Introduction Several major chemical catastrophes have demonstrated the need for effective PSM and the potential devastation of a dysfunctional system Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 13 A few major industrial accidents INCIDENT EFFECTS Bhopal, India, 1984 Union Carbide Methyl Isocyanate Release >3800 fatalities, >100 000 injuries, severe damage to area livestock and crops, long term health effects, $470 M compensation Chernobyl, USSR, 1986 Nuclear Reactor Meltdown 30 acute fatalities, >130 000 people exposed to harmful radiation, long term health affects, permanent evacuation of the city 11 fatalities from the explosion Extensive environmental damage, extensive damage to regional fishing and tourism industry, >$4.5 B USD in fines, >$42 B in civil settlements Loss of crew (7 fatalities), loss of space shuttle (>$8 B USD), recovery of debris Gulf Oil Spill. USA, 2010 British Petroleum Deepwater Horizon Oil Platform Explosion and Spill Challenger Disaster, USA, 1986 NASA Explosion [8, 9] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 14 Bhopal India, 1984 Union Carbide Corporation operating in Bhopal manufactured methyl isocyanate (MIC) as a precursor in Sevin (insecticide) production [8, 9]. Over >40 tons of MIC leaked into the air and caused over 3800 immediate fatalities and countless injuries and long term health affects. MIC tanks after Bhopal incident. (Wikipedia commons) Introduction Commitment to PSM Hazard & Risk Assessment Management had intentions to permanently shut down uneconomical operations and while many safety designs were not kept in operation even though a substantial MIC inventory was still in place Risk Management Enhancing PSM 15 On the night of the accident, approximately 2000 L of water was introduced into the MIC storage tanks causing an exothermic reaction to produce MIC vapours and increased pressure [8]. How did this happen? There is no consensuses on how the water was improperly introduced into the tanks. Some suggestions include valve malfunction or sabotage. Regardless, safety considerations had been made in the design of the plant. The MIC storage tanks were equipped with a soda scrubber, a refrigeration system, and temperature and pressure alarms. However, the scrubber was out of service. The flare, being the last defence, was also not in service. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 16 Production had been halted 6 months prior to the accident and the downstream Sevin plant continued to operate using the stored MIC. This indicated that considerable amounts of MIC a highly toxic chemical was being stored for extended period of time. How did this happen? Introduction Inherently safer design (ISD) dictates that inventory of highly toxic materials should be maintained at the lowest possible level to minimize the possibility of large releases. Also, newer technology was later developed to produce the same pesticide product without using MIC intermediate, thus employing the ISD principle of substitution. Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 17 Accountability and corporate commitment to safety failed when supervisors failed to take immediate action when workers first reported a burning sensation in their eyes. Why did this happen? (In terms of PSM) Introduction No management of change system was used to evaluate the effects of shutting down the safety equipment such as the refrigeration system, the soda scrubber and the flare system while continuing to store a significant amount of MIC on-site. Equipment integrity and operating procedures were not maintained and as a consequence the pressure alarms had become so unreliable they were ignored by workers, the temperature alarms had failed to operate, and the tanks were filled beyond their recommended capacity Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 18 Flixborough, UK, 1974 Napro UK located in Flixborough manufactured caprolactam a precursor for nylon synthesis [4,8,9,10]. An improperly designed bypass line caused the leakage of a 50 ton cyclohexane vapour cloud in seconds Allen, B. (2011). Flixborough: The price of nylon. Health and Safety at work. Upon contact with an ignition source, the resulting explosion killed 28 employees and damaged over 1800 buildings in the surrounding area. Link to official report http://www.catastrophic-events.com/docs/Flixborough.pdf Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 19 Prior to the accident, a crack in the reactor used for the oxidation of cyclohexane was discovered. The maintenance engineer on-site decided to install a bypass line in order to maintain production and reduce down time. How did this happen? However, the site experienced mechanical engineer had quit some time before, and those remaining decided to “fast track” a solution for the by-pass. For design, they sketched a full-scale by-pass line in chalk on the maintenance shop floor. However, no stress and thrust force analysis calculations were performed on the by-pass line. The bypass later ruptured and leaked hot cyclohexane into the vicinity which ignited resulting in the explosion. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 20 A functional PSM system would require a management of change system to deal with process design changes. Why did this happen? (In terms of PSM) Introduction Every facility must ensure that competent personnel are hired and trained for the positions they fill. Proper management of organizational change would have identified that the maintenance engineer, and the laboratory manager who also reviewed the shop floor sketch design, were unqualified Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 21 What are some of the consequences of major hazard incidents? Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 22 Health and Safety Workers are at highest risk of injury since they are at the “front line.” The public while not on-site is at risk when a serious major disaster occurs. Worker • • • • Death Severe injury Long term health problems Affects personal monetary success if injuries and health problems interfere with future work Public • • • • • • Death Severe injury Long term health problems Economic problems Community longevity Environmental health will also affect the public’s health and safety Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 23 Environmental Impacts [9] Environmental damage caused by major disasters can harm residents’ health as well as lead to reduced longevity of the community Atmospheric • • • Contamination of air quality used by humans, animals and vegetation Contamination of property (e.g. soot) Interference of normal quality of life and business Aquatic • • Contamination of water used for drinking, irrigation and recreation Harm to fish and wildlife Terrestrial • • Contamination of land and vegetation Property damage Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 24 Corporate Losses [11,13] A major disaster can completely ruin a company. At minimum be severely detrimental to the well being of the organization and thus the employees Clean Up • Clean up of the Deep Horizon spill & legal settlement fees cost >$14 B USD Insurance • • • A poor safety record increases premiums on assets A poor safety record increases the number of health claims Large amounts of claim settlements cause higher premiums Reputation • The international news reporting ensures the disaster will be seen by consumers around the world May cause consumer boycott Reputation as an employer that values safety • • Productivity • Will decrease productivity and therefore profits if a facility is not operational Product Quality • • May decrease quality if facility is not operating at top quality May cause pressure on other facilities decreasing their quality Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 25 PSM systems are typically centered around four themes [4]: i. Commitment of management and corporate objectives to PSM The Elements of PSM ii. Hazard assessment, including process knowledge and hazard identification iii. Risk management such as managing change in the process and change in personnel iv. Continuous enhancement such as furthering employee education and enhancing process knowledge THESE ARE THE TITLES OF THE REMAINING SECTIONS OF THIS MODULE…. CLICK TO NAVIGATE Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 26 PSM System Possible Elements [1, 2, 4] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 27 Risk is never zero. Two of the most important features of a PSM system are participation and communication Although PSM systems are typically designed by management they require input from operators and commitment from corporate executives to be implemented properly PSM systems are non-prescriptive [13] They must be based on performance indicators to measure the success of the PSM system Guidelines can be implemented in many ways as long as the objectives are met Finally, PSM systems are not created once and implemented once. They are an on-going process that involves auditing and revaluation of the management system to continually enhance the effectiveness of the PSM system. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 28 Process Safety Management Systems from around the world American Occupational Health and Safety Administration Process Safety Management Rule enacted in 1994 14 Elements - CSChE – The Canadian Society for Chemical Engineering [1] 20 Elements - AIChE CCPS – The American Institute for Chemical Engineers Center for Chemical Process Safety [4] 12 Elements – OSHA – US Occupational Health and Safety Administration PSM Rule 1910.119 [3] 20 Elements – EU Energy Institute [2] Some large corporations may also sell their custom systems or services for implementing PSM Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 29 While no specific regulations to implement PSM in process facilities in Canada currently exist, nonetheless, “due diligence” does require companies to make their processes safe Commitment to Best Practices Negligence or ignorance and failure to do a proper assessment to prevent an incident can be a criminal offense as described in the Criminal Code. Bill C-45 – Amendment to the Criminal Code of Canada: "217.1 Every one who undertakes, or has the authority, to direct how another person does work or performs a task is under a legal duty to take reasonable steps to prevent bodily harm to that person, or any other person, arising from that work or task.“ [14] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 30 Bill C-45 was passed as a result of the Westray Mine Explosion in Nova Scotia, 1992 About 8 months after the mine was opened, an underground methane explosion killed 26 workers who were underground at the time. There were no survivors underground [15]. Westray Bill A public inquiry found that the mine was poorly managed, worker safety was ignored, and poor oversight by the government regulators were the causes of the worse mining disaster in Canada A criminal case was pursued against two managers but was dropped when it became unlikely they would be convicted. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 31 Responsible Care The Chemistry Industry Association of Canada (CIAC) promotes PSM as part of their Responsible Care program for their members [6]. Many companies may possess facilities in the United States which are required by law since 1994 to have a functioning PSM system and are therefore experienced with the development and implementation of these systems. http://www.canadianchemistry.ca/ResponsibleCareHome.aspx Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 32 Two major international drivers of PSM: US OSHA PSM Standard 1910.119 [16] PSM around the world With the US OSHA levying hefty fines in the past few years, the need for functional PSM systems is increasing While no fines will be levied for failure to possess a functional PSM system in Canada, there are still legal requirements for all people directing work to take reasonable steps to ensure worker and public safety EU Seveso II Directive [17] Directive II was a revision of the original directive which increased the requirement to include a safety management system, as well as emergency and land-use planning 33 In the event of a loss of containment, the criminal code of Canada states that there will be severe penalties for failing to ensure the safe operation of facilities and ensure operational integrity [14]. PSM in Canada Environment Canada’s Environmental Emergencies regulation requires hazard assessments to prevent spills, which is the focus of PSM. Ontario Environment Regulation 224 requires risk assessment of potential spills and a contingency plan Alberta Strathcona County has bylaws requiring riskbased land use planning adjacent to hazardous Other bylaws and regulations may exist and should be evaluated for every facility Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 34 Summary How do we prevent a loss of containment incident? Maintain process integrity Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 35 References 1. Canadian Society for Chemical Engineering. Process Safety Management Guide. Ottawa : Canadian Society for Chemical Engineering, 2012. 2. Energy Institute. High Level Framework for Process Safety Management. London : Energy Institute, 2010. 3. U.S. Department of Labor. Process Safety: (OSHA 3132). s.l. : U.S. Department of Labor, 2000. 4. Center for Chemical Process Safety. Guideline for Management of Change for Process Safety. New York : John Wiley & Sons, Inc, 2008. 5. Government of Canada. Canada Environmental Protection Act, 1999. Environment Canada [Online] 07 10, 2013. http://www.ec.gc.ca/lcpecepa/default.asp?lang=En&n=E00B5BD8-1 6. Chemistry Industry Association of Canada. Responsible Care. Chemistry Industry Association of Canada. [Online] 07 10, 2013. http://www.canadianchemistry.ca/ResponsibleCareHome.aspx. 7. Government of Canada. Canada Occupational Health and Safety Regulations (SOR/86-304). Justice Laws Website. [Online] 07 10, 2013. http://lawslois.justice.gc.ca/eng/regulations/SOR-86-304/. 8. Atherton, John and Gil, Fredric. Incidents that define process safety. Hoboken, NJ : John Wiley & Sons, Inc, 2008. 36 9. Kletz, Trevor. What went wrong? Case histories of process plant disasters and how they could have been avoided. 5th. Oxford : Elsevier, 2009. 10. Oxford Economics. Potential Impact of the Gulf Oil Spill on Tourism. Washington : US Travel Association, 2010. 11. Health and Safety Executive. The Flixborough Disaster : Report of the Court of Inquiry. London : Her Majesty’s Stationery Office National Archives, 1975. 12. Turk, M.A. and Mishra, A. Process Safety Management: Going Beyond Functional Safety. Hydrocarbon Processing. [Online] 07 23, 2013. http://www.hydrocarbonprocessing.com/Article/3161534/Process-safetymanagement-Going-beyond-functional-safety.html. 13. Sutton Technical Books. Process Safety Management. Sutton Technical Books. [Online] 07 23, 2013. http://www.stb07.com/process-safetymanagement/process-safety-management-index.html. 14. Department of Justice, Government of Canada. Plain Language guide to Bill C-45. http://www.justice.gc.ca/eng/rp-pr/other-autre/c45/. Accessed: May 30, 2013. 37 15. Government of Nova Scotia. The Westray Story: A predictable path to Disaster. http://novascotia.ca/lae/pubs/westray/. Accessed: June 2, 2013. 16. U.S. Department of Labor. Process Safety: Regulation 1910 : U.S. Department of Labor, 2000. [Online] https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STAND ARDS&p_id=9760 17. European Commision. EU Seveso II Directive. European Commision , 2013 [Online] http://ec.europa.eu/environment/seveso/index.htm 18. Busick, Jennifer. Process Safety Management. SAFETY COMPLIANCE LETTER. pp. 5-6. 19. Kelly, Brian D. Process Safety Management and its impact on the professional engineering community. Calgary, Ontario, Canada : s.n., 2010 38 Commitment to Process Safety Process Safety Culture Compliance with Standards Process Safety Competency Workforce Involvement Stakeholder outreach 39 Evolution of organizational culture [1, 2] Commitment to process safety Introduction Confrontational/Enforcement ↓ Cooperative/Collaborative Develop safety culture to consistently follow existing standards, involve the entire workforce and communicate with stakeholders Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 40 1. Process Safety Culture The way in which safety is managed and perceived in a workplace 41 The goals of a sound process safety culture are to [1]: Monitor and maintain a sound safety culture Process Safety Culture Introduction Support the consistent operation of the process This is achieved by providing strong leadership and direction, prioritizing process safety, providing sufficient resources, and establishing performance standards and enforcing them. Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 42 What does a strong safety culture look like? Weak Culture Strong Culture • Assigns little value to process safety • Has poor sense of process safety vulnerabilities • • Devotes minimal resources to process safety • • Overlooks small indications of process safety problems • • Accepts or normalized increasingly poor safety • performance Relies solely on few individuals or management • to determine process safety hazards and risk management activities • Introduction Commitment to PSM [1] • Integrates process safety into the core values of the organization Focuses on potential failures and strives to understand the risk and means of controlling it Seeks to provide resources proportional to the perceived needs Places emphasis on learning from mistakes in order to prevent future problems Seeks to continuously improve process safety performance Employees of all levels are involved in hazard identification and addressing the risks. Employees take action to address hazards at all levels Hazard & Risk Assessment Risk Management Enhancing PSM 43 [3] STRONG Organizational Culture Tribal Operational Excellence Chaotic Bureaucratic People WEAK Introduction Commitment to PSM WEAK Systems STRONG Hazard & Risk Assessment Risk Management Enhancing PSM 44 Strong leadership is required in order to establish process safety as a core value of the organization An essential feature of good safety leadership is CREDIBILITY: What you say must be aligned with what you do Senior & middle management must be on the same page Executives and CEOs must possess strong will to make the right decision in the face of demands from shareholders and stakeholders Providing strong leadership Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 45 What gets rewarded gets done A balance of direction on production, facility, personnel, and safety must be given in order to prevent a reordering of priorities amongst middle managers and supervisors [2] Providing direction When leaders focus exclusively on production, this indirectly communicates that production should take precedence over everything else This inhibits proactive preventive behaviours and encourages a reactive culture Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 46 • A strong safety culture establishes a strong intolerance for any violations of safe practice in order to reinforce safety as a core value Establishing process safety as a core value “A practitioner [engineer] shall, regard the practitioner’s duty to public welfare as paramount” - Professional Engineers Ontario Code of Ethics [4] Engineers should always be reinforcing the organizations’ commitment to safety throughout their professional activities Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 47 Identifying your type of safety culture [2] Generative Proactive Calculative Reactive Pathological “Safety is how the business is run” “Safety is managed by workforce involvement” “Safety is managed by procedures & documentation” “Safety is only an issue if something happens” “Who cares as long as you don’t get caught” Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 48 Leadership is the most important variable in changing safety behaviours. Leadership in process safety Introduction A good safety leader [2]: Prioritizes safety Sets safety targets Creates the safety vision Provides compelling direction Provides sufficient resources (such as people, time, money, or information) Weathers the impact of shareholder/stakeholder punishment on investments on improving safety and quality until it gains support upon maturity Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 49 2. Compliance with Standards Following the law, rules, and regulations as well as any existing professional or design standards 50 This is a fundamental requirement for organizations [5] Compliance with standards Relevant rules, regulations, and standards must be: I. Identified II. Understood III. Implemented or confirmed Non-compliance typically results in fines but can also lead to serious accidents Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 51 Why should you comply? Because tragic accidents have taught us they could have been prevented if best practices were followed Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 52 Licensing What types of regulations & rules exist? Introduction Permit systems Codes for equipment Pressure vessels Piping, etc. Government requirements Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 53 3. Process Safety Competency Process safety competency focuses on organizational learning. It is distinct from the training and knowledge elements which focus on cataloguing and storing information and maintaining worker competency respectively. 54 The main purpose is to UNDERSTAND What is the purpose of process safety competency? Introduction The purpose of process safety competency is to proactively increase the body of knowledge of an organization prior to any incident occurring [1] Additionally, this knowledge seeking must be supported by management and applications of newly acquired knowledge should be encouraged in order to reduce risk and increase process safety Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 55 Positive Learning Culture [1,6] Establishes and periodically updates the learning plan Supports discussion and evaluation of divergent opinions and data Help focus the efforts to increase competence Stimulate new ideas Provide timely feedback Allow feedback on the means to improve how work activities are approached Tolerating errors Commitment to PSM Don’t depend only on incremental approaches to improve PSM Maintains an external focus Ideas from outside the organization are not automatically discounted Learns from errors. Failure to encourage innovation stifles improvement Introduction Recognize and accepts differences Hazard & Risk Assessment Risk Management Enhancing PSM 56 Negative Learning Culture [1,6] Blind spots Narrow focus and poor assumptions allow disruptive technologies Flawed interpretation Poor logic due to lack of information or emotional bias Filtering Downplaying information that doesn’t fit in the existing paradigm Inaction Unwilling or unable to act Lack of information sharing Hoarding information and poor sharing Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 57 4. Workforce Involvement Involving all levels in the activities of process safety management 58 The purpose of workforce involvement is engage employees of all levels in the development or revaluation of PSM elements Purpose of workforce involvement The workforce also includes and contract workers that will be affected by facility operations Employees at different levels will contribute different information about the process that is necessary in order to create an effective PSM system Frontline workers may be the best authority on day to day operations and routines Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 59 How to do you involve people in PSM? Introduction Provide specific PSM responsibilities to their roles [1, 7] Provide a mechanism for individuals to communicate their concerns or observations Allow individuals to participate in protecting their own welfare Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 60 Individual empowerment [1,2] Everyone should feel they have a say in their own welfare and safety Deference to expertise Benefits of workforce involvement Recognize expertize or lack of it when evaluating process safety Open communication Encourage participation in safety discussions May be that only 1 person realizes the risk Mutual trust Foster trust between workers and management Responsiveness Improve participation in safety by providing sincere timely response to PSM input or concerns Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 61 It applies to all elements! Generally is involved in all aspects of PSM and not really specifically addressed by this element alone Element specific activities may involve periodic opinion surveys Evaluation of worker involvement Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 62 5. Stakeholder outreach Providing a means of communication for the concerns of any stakeholders 63 Who may be affected by your facilities operations? Government Officials Non-government associations • Local councils • Politicians • Regulators Emergency Response Services • Business/Industry associations • Environmental groups • Youth groups Other • Residents • Post-secondary institutions • Local school boards • Fire • Paramedics • Police Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 64 Why is stakeholder outreach an element of PSM? Following the events of Bhopal, India, it was evident that the potential for damage to the surrounding community was immense and that chemical producers had an obligation to hear the concerns of the community The Chemistry Industry Association of Canada (formerly the Canadian Chemical Producers Association) created a mandatory initiative called Responsible Care which calls for Community Awareness & Emergency Response practices http://www.canadianchemistry.ca/ResponsibleCareHome.aspx Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 65 The main objectives of the outreach element are to [1]: Goals of stakeholder outreach Introduction 1. Identify and engage the community and other stakeholders in discussions about process safety 2. Establish a mode of communication for any concerns of needs stakeholders may want addressed 3. Use the establish mode of communication to follow up on any aired concerns Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 66 TRUST Public discussion and openly addressing concerns builds trust with the stakeholders [2] Benefits of stakeholder outreach It is important for residents to feel confident that the organization is taking reasonable care to operate in a safe and environmentally sound way Promoting transparency and responsiveness will increase the stakeholders confidence in the company [1] This in turn may lead to the stakeholders willingness to cooperate in the future Stakeholders will know how to contact the company should the need arise Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 67 Communications personnel, phone operators, security guards, legal staff [1] Who does this? Key personnel should receive communications training in order to prepare them to hold planned events to press conferences Legal personnel must give guidance to communications personnel in order to protect confidential business information while providing the appropriate information for any concern Any additional staff such as those responsible for emergency response planning Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 68 Organizing your outreach system Introduction How an organization pursues their outreach will depend on the size of the facility and the potential risks for the community [1]: Combine with other industrial partners in the area Emergency response may require a separate outreach format than other stakeholders Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 69 The outreach program will also be used in the aftermath of an incident should one occur [1,2] Press Conferences Introduction By engaging the public in the outreach program prior to an incident, in a state of emergency, the public will already be aware of the communication plan of the facility Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 70 [1] Center for Chemical Process Safety. Guidelines for Risk Based Process Safety. New Jersey : Jon Wiley & Sons, 2011. [2] Lutchman, C. et al. Safety Management: A comprehensive approach to developing a sustainable system. London: CRC Press,2012) [3] Ian Sutton. (2010) Process Risk and Reliability Management: Operational Integrity Management. Elsevier. References [4] Professional Engineers Ontario Code of Ethics, Section 77 of the O. Reg. 941 [5] Energy Institute. High Level Framework for Process Safety Management. London : Energy Institute, 2010. [6] Is yours a learning organization? Garvin, David A, Edmondson, C Amy and Gino, Francesca. 2008, Harvard Business Review, pp. 1-11. [7] Canadian Society of Chemical Engineering. Process Safety Management Guide. Ottawa : Canadian Society of Chemical Engineering, 2012. 71 Hazard and Risk Identification Process Knowledge Management Hazard Identification and Risk Analysis 72 This pillar of PSM has two elements [1]: Hazard and Risk Identification Introduction I. II. Process knowledge Hazard Identification and Risk Assessment These two elements will form the bases of your risk management activities and therefore, comprehensive knowledge of your process and proper identification of hazards and their risks is crucial to PSM. Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 73 6. Process Knowledge Identification and documentation of all relevant process knowledge for use in other PSM elements 74 This element boils down to three things: Process knowledge Management Introduction i. Understanding your process ii. Documenting your understanding iii. Managing the documentation process The results of this element should be [1]: Commitment to PSM (1) Accurate, complete, up-to date information about your process (2) A documentation system Hazard & Risk Assessment Risk Management Enhancing PSM 75 What kind of knowledge is necessary? [1] Chemical materials Hazard information, MSDS Sheets Reaction chemistry Kinetics, thermodynamics, calculations Process Knowledge Process conditions Equipment design Design, fabrication and installation Engineering drawings & calculations Piping & Instrumentation Diagrams (PI&Ds) Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 76 Managing your documentation Documentation and access of information is just as important as understanding your process [1]: Information that is up to date must be protected Access must be protected to avoid inadvertent change Scheduling a cycle for updating documentation may help Out of date information must be retrieved and controlled Access must be controlled to avoid circulation of incorrect knowledge Only kept for archival purposes Knowledge must be documented in a usable and easily retrievable manner, a.k.a user friendly Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 77 Consequences of poor process knowledge management Process knowledge is critical to identifying the hazards and risks of a process Example: Hydroxylamine explosion, Pennsylvania 1999 [1] 4 employee fatalities, 1 employee of an adjacent business killed 14 injured, extensive damage to the area Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 78 Knowledge Translation Very first pilot scale batch of hydroxylamine distillation in this facility It was documented that hydroxylamine in solutions of >70% (w/v) undergo explosive decomposition The process was designed to distill hydroxylamine to 85% (w/v) Knowledge was not properly managed Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 79 7. Hazard Identification and Risk Analysis Identify process hazards and evaluate process risks. 80 These terms are often used interchangeably, however they are not the same thing [1] Hazards & Risks A hazard can be any chemical use, physical action, mechanical process, etc. that could, upon a failure event, cause damage to a person(s), property, or the environment Risk is the probability that someone, property or the environment may suffer harmful consequences as a result of exposure to a hazard Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 81 Car accidents • A car accident is a common physical hazard we have all seen. Lets specifically refer to one car hitting another car. Example: Car Accident • The risk of being in a collision is dependent on several factors; road conditions, driving ability, vehicle engineering design, etc. • However, in general, you might have (for example) a 1:1000 person chance of being in a collision. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 82 The only way to have zero risk is to never ride in a car so you can never be involved in a car/car collision. Zero Risk The likelihood that you will never get in a car is pretty much zero (in Canada). So this is rarely true. If a process is operating, the risk can never be zero. The only way to eliminate process risks is to never run the process. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management You can’t lose if you don’t play! Enhancing PSM 83 The consequences will depend on your speed, road conditions, vehicle design, etc. Severity or Consequences Therefore, the bigger the consequences the higher the risk. E.g. the faster you are going, the worse you could get hurt so you are taking a larger risk. This is called the severity : 𝑅𝑖𝑠𝑘 = 𝑃𝑟𝑜𝑏𝑎𝑏𝑖𝑙𝑖𝑡𝑦 𝑥 𝑆𝑒𝑣𝑒𝑟𝑖𝑡𝑦 Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 84 𝑅𝑖𝑠𝑘 = 𝑃𝑟𝑜𝑏𝑎𝑏𝑖𝑙𝑖𝑡𝑦 𝑥 𝑆𝑒𝑣𝑒𝑟𝑖𝑡𝑦 Two possibilities: Increasing Risk a. ↑ probability = ↑ risk E.g. probability of a collision is higher in winter; so the collision risk is higher b. ↑ severity = ↑ risk E.g. the accident’s severity is worse if you don’t wear your seatbelt; so the collision risk is higher Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 85 Why is hazard identification important? If you don’t know what the risks are, you can’t manage them! What is the risk that the dealer has blackjack? Should you take the risk and bet? Does the risk change if the stakes are high? Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 86 PERCEIVED RISK vs. ACUTAL RISK Risk • Incorrect hazard identification or risk assessment can lead to unknowingly accepting more risks than the company or community has deemed acceptable. • It can also waste time & money! Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 87 Risk Assessment Matrix Consequences Catastrophic ← Serious ← Negligible High ↑ Frequency Moderate ↑ Low The unacceptable risk region is set by an organization’s risk tolerance criteria This table describes the basics of risk assessment. For example, If the risk falls into the black zone, it’s not an acceptable risk, however, in between are lots of shades of grey. Risk analysis determines the expected frequency (or likelihood) as well as the severity for a particular consequence Risk assessment compares the risk result level to an acceptable risk criteria Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 88 Residual risks The risk you are willing to tolerate to operate your facility For example there is always an inherent risk will building a new fertilizer plant Introduced risks Risks which are introduced during the lifecycle of a process New equipment or changes in personnel Four Types of Risk [4] Operating risks Risks caused by your operational procedures Normalized risks Risks that are deviations from the normal risk but become normalized over time. Caused by incomplete understanding of the actual risk. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 89 Some of the many TOOLS of PHA [1] Simple hazard identification: Process Hazard Analysis (PHA) Hazard and Operability Analysis (HAZOP) Failure Modes and Effects Analysis (FMEA) What If Studies Simple risk analysis: Layers of Protection Analysis (LOPA) Failure Modes, Effects, and Criticality Analysis (FMECA) Detailed quantitative risk analysis can use: Fault Tree Analysis (FTA) Monte Carlo Simulation and Markov Analysis Quantitative hazard effects analysis Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 90 The need for a PHA is usually assessed by a steering committee who have identified a need for PHA in some areas PHAs are typically administered by a team lead Who conducts a PHA? Engineers, Operations, and Maintenance staff will all be involved from necessity in generating the information required for a PHA The team lead will gather the data and the information and recommendations are reported to management Senior management will ultimately make a decision on any policy changes Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 91 Three general categories [3]: Logical/Rational How do you identify hazards? Usually used for detailed PHAs E.g. Fault Tree Analysis is logical Experience-based Moderate depth, such as checklists. Known scenarios maybe from historical events at the facility or similar facilities Creative/Imaginative What if analysis identifies new scenarios Broad general PHAs require this Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 92 Although we are trying to prevent serious consequences from occurring in a process; in the PHA, the causes can be relatively minor Scope of PHAs Does not refer to work place safety concerns such as falling off a ladder and wearing PPE, unless they are a potential cause in a larger hazard (very rare) In general, PSM is concerned with loss of containment hazards, their causes and maintaining process integrity Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 93 Loss of Containment: Chemical Release Spills Energy Release Thermal (e.g., Fire) Physical (e.g., Explosion) Nuclear (e.g., Radiation) Potential Process Hazards Special Case – Runaway Reactions Thermal runaway reactions (E.g. Chemical reactions or nuclear reactions) A special case for the process industries which manufacture chemicals Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 94 Hazard: Chemical Release Release of a hazardous chemical Environmental damage tao55 / FreeDigitalPhotos.net Damage to community health and welfare Sujin Jetkasettakorn / FreeDigitalPhotos.net Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 95 Nuclear Mechanical (kinetic) Electrical Hazard: Energy Release Chemical jscreationzs/ Freedigitalimages.net Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 96 An energy release from these sources can result in a: Hazard: Energy Release Fire (thermal energy) Explosion (mechanical/ kinetic energy) (may have many ways of starting from various sources) Radiation (nuclear energy) Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 97 FIRE = FUEL + OXYGEN + IGNITION Fuel: Hazards: Fire Volatile Liquids Aerosol Dust Combustible aerosols and dusts can ignite more easily than some liquids. Note, not commonly known: No liquid or solid can burn! Only the vapour on the surface of the liquid/ solid, created by heat from the ignition process, burns. The resulting fire sustains vapour development. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 98 Fires are often started for free: Hazards: Fire Heat (auto-ignition) Open flames (welding, heaters, etc.) Electrical (sparks, static, lightning, etc.) tiverylucky / FreeDigitalPhotos.net Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 99 A rapid release of energy manifested by high pressure and high temperature [4] Chemical – Rapid oxidation reaction (often started by a flame) Hazard: Explosion Mechanical or Vapor – Sudden rupture of mechanical containment due to increased pressure or weakened container wall Nuclear – Fission based explosion which cannot happen outside of a weapon specifically designed for this purpose (won’t happen in a nuclear power plant) Electrical – High current electrical fault which instantly vaporizes metal and insulating materials Magnetic – Magnetic pressure caused by ultra strong electromagnets (unlikely to happen in a chemical process plant) Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 100 Initiating Causes While loss of containment of chemicals and energy can lead to these hazards, often there is an initiating cause that may not be directly related: Equipment failure Human errors External “acts of god” Inclement weather (Tornado, hurricane, etc.) Plane crash Alien invasion Missile Attack dan/ FreeDigitalPhotos.net Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 101 This is a particular worry for chemical process industries Special Case: Thermal Runaway Thermal runaway reactions are a feedback loop whereby heat is generated by a reaction which increases the reaction rate which thereby creates more heat at a greater rate, etc. The reaction goes out of control, often resulting in an explosion This is most often caused by failure of the process heat removal system Introduction Commitment to PSM Hazard & Risk Assessment (Wikipedia commons) Risk Management Enhancing PSM 102 Hazard: Runaway Reaction “A chemical reaction process which accelerates out of control in consequence of the release of chemical energy at a rate which exceeds that which it can be removed from the system by heat transfer operations” [4] The term “runaway reaction” is specific to reactions in vessels (because technically that definition is true for a fire) This hazardous event has been seen in many industrial accidents and is technically avoidable with sound engineering design, but sometimes these may be caused by human factors Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 103 Hazardous Event Probability and Time Line Inherent Potential Hazard Initiating Causes Freq. of initiating cause (process control failure or procedural error) Hardware Defense Prob. of failure of interlock and mechanical safety devices Initiating Cause Operational Hardware Failure Failure Mechanical Loss of Failure Operational Defense Containment Prob. of failure to respond to process alarms Hardware Failure Prob. of mechanical integrity breach Loss of Containment Hazardous Event Freq. of loss of containment Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 104 Using PHA information Introduction Once you know the hazards what do you do with the information? Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 105 Management and PHAs Management is typically not just engineers that understand the process. Decisions are made for the facility based on competing interests PHAs that are accurate can be useful and necessary to help management from making poor decisions Managers have to make decisions based on competing interests Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 106 Finances Productivity Competing Interests Quality Consistency DECISION Safety Regulatory Requirements Introduction Commitment to PSM Hazard & Risk Assessment Customers Stakeholders Risk Management Enhancing PSM 107 Engaging the workforce Senior Mmgt Fallible Decisions Middle Mmgt Engineers Latent Failures Preconditions Supervisors Operators Unsafe System Acts Hardware Failures Defense Accident Management decisions are critical [5] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 108 Assessing risk is not simple. Different people will have different opinions about severity and maybe even frequency if it not easily quantified. Risk is mutable Introduction Low frequency: Runaway reaction Should you protect your plant from a plane crash? Should you protect from natural hazards not typical to your region? (e.g., hurricanes) Should you protect against missile attacks? Should you protect against a meteorite crash? Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 109 Risk Management Risk can be controlled by operating practices and process design… a.k.a Risk Management Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 110 [1] Center for Chemical Process Safety. Guidelines for Risk Based Process Safety. New Jersey : Jon Wiley & Sons, 2011. [2] Photo Credit: Tom Volk/The Morning Call. http://www.mcall.com/all-concept1,0,7393.photo References [3] Ian Sutton. (2010) Process Risk and Reliability Management: Operational Integrity Management. Elsevier. [4] Vic Marshall and Steve Ruhemann. (2001) Fundamentals of Process Safety. iChemE. [5] Knegtering & Pasma (2009). Safety of the process industries in the 21st century: A changing need of process safety management for a changing industry. J Loss Prevent Proc Ind. 22; 162-168. 111 Risk Management Operating Procedures Management of Change Safe Work Practices Operation Readiness Asset Integrity and Reliability Conduct of Operations Contractor Management Training and performance Assurance Emergency Management Risk Management Risk can be managed in many ways. Generally the sooner in the process life cycle you implement a risk management decision, the cheaper it is. The most cost effective time to implement safety features is during the design process Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 113 Use of Inherently safer design (ISD) principles seeks to avoid hazards rather than control them with added-on protective equipment [1, 2] Minimize: Reduce inventories of hazardous materials on site Substitute: Replace hazardous substances, equipment or operations with less hazardous ones whenever possible Inherently Safer Design Moderate: Use less aggressive operating conditions Simplify: Only use necessary operations. Remove issues by design not by the addition of consequential process operations Other strategies employed by ISD Design and locate equipment such that: Minimize transportation and storage of hazardous materials if possible Locate equipment and materials such that in the worst possible scenario the least amount of damage is done Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 114 Once upon a time a king offered three young men an opportunity to take a chance for true love. They could open one of two doors. [1] Behind one door was a dragon. Behind the other was their true love. A tale of RISK Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 115 The first man decided not to take the risk. He lived safely until the end of his days but he never found love. Inherently Safer Design The second young men hired some risk professionals. They collected data on the tiger and the true love, built machines to detect the sounds of a dragon and calculated the probability. Naturally this took time and money and the by the time the consultants were ready to advise the man he was old and poor. Regardless he opened the recommended door and got eaten by a low probability dragon. The third man took a course in dragon slaying. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 116 8. Operating procedures This element focuses on documenting written procedures, maintaining them, and consistently using them to maintain facility integrity 117 Current Three Goals Accurate Useful Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 118 Normal operations What types are covered? Introduction Infrequent operations Special high hazard procedures Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 119 Ways to write procedures [3] Narrative Written in long paragraphs, difficult to follow (most common but avoid this if possible) Flowchart Graphical depiction with brief descriptions Checklist Paragraph Basic actions with spots to initial or check off actions Similar to narrative but given some structure through numbering Playscript Outline Short sentences with number or indentation structure to group information For multiple operators that need to perform tasks together T-Bar Multi-Column Multiple compartments of information usually used for troubleshooting guides Introduction Commitment to PSM Hazard & Risk Assessment Two columns one with steps, other with details or special instructions Risk Management Enhancing PSM 120 For each step in a procedure, the following should be outlined in the written protocol [3]: Contents of a Procedure Introduction Commitment to PSM Any expected system responses (or none) Indicators that the step was performed properly Possible consequences if the step was not performed properly Safe operating limits Consequences of deviating from limits Any limiting conditions Address what procedure should be followed if deviations from the limits is detected Hazard & Risk Assessment Risk Management Enhancing PSM 121 Validation & Maintenance Written operating procedures must be used consistently, therefore it is important to validate that they conform to the actual procedures used. [3] However, the correct and safe practice should be the one finally reflected in the procedure and should be implemented if not in actual practice. Once they are implemented, ask for feedback from the operators to correct any errors or omissions. Procedures must be available to those using them and those you may need to use them infrequently. They should be updated & reviewed regularly Old procedures must be controlled to ensure that only the correct practices are being used. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 122 9. Safe work practices This element focuses on using safe work procedures during maintenance or nonroutine work. 123 This does not refer to the frequency of the task Non-routine work Introduction Any work that is not a part of the normal operating process [3]: Commitment to PSM Inspections Calibrations Repairs Testing Maintenance activities (specific procedures are covered in the maintenance element) Hazard & Risk Assessment Risk Management Enhancing PSM 124 Three sets of procedures will help cover all possibilities and reduce risk: Operating procedures (Element 8) Normal process operations Cover all your bases Safe work practices (Element 9) Non-routine work Maintenance procedures (Element 10) Maintenance of equipment (routine but not part of normal operations) Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 125 Non-routine work should use a permit system which must be authorized and confirmed with the correct personnel prior to the activity being undertaken [3] Work Permits Operators Technicians Performing Work Permits are updated at each shift change Permits also ensure the appropriate locks on valves or switches are in place prior to the work taking place Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 126 Permits will require that safe work procedures are used and this may involve placing a fire blanket when welding to prevent ignition, for example [3] Other Things Work Permits Control Confined space entry Hot work (Fire hazard) Welding, cutting with no fuel source present When flammables are present, welding, drilling, grinding become an ignition hazard Opening vessels, lines, etc. Lock outs (electrical, valves. etc.) Construction (inside or adjacent to operating areas) Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 127 Piper Alpha Oil Platform Explosion, 1988 The explosion at Piper Alpha was caused by improperly managed safe work practices for example, safety valve inspection/ testing. An offshore oil rig exploded resulting in 167 deaths and $1.7 B dollars in damage [3] The explosion was caused by a hydrocarbon leak due to the removal of a safety valve on a pump which was removed for inspection/ testing and not reinstalled prior to the shift change. The pump had been taken out of service earlier that day for maintenance work The night crew was aware of the maintenance work and had to authorize electricians to resupply the pump with power in order to return it to service It is unclear if the night crew knew that the maintenance was incomplete Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 128 10. Asset integrity and reliability This element focuses on the design, installation and maintenance of equipment from when it is fabricated to its retirement to ensure it is fit for use 129 VERY important element Critical Element Covers a major desire in process safety: MAINTAIN PROCESS INTEGRITY Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 130 This has been a leading cause of accidents in the process industries [3] Poor design Poor installation Poor maintenance Equipment Failure Undetected deterioration Improperly performed maintenance Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 131 Managing asset integrity Inspections Testing Certifications This is one of the two primary responsibilities of a process facility [3]: (1) Preventing a loss of containment incident (2) Ensure the dependability of critical systems that prevent these types of events Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 132 American Airlines Flight 191, 1979 Deadliest air crash in the US, 273 fatalities [1, 4] Caused by improper maintenance procedures In an attempt to save time and money, the airline instructed maintenance mechanics to remove the engine and pylon together instead of doing it separately as indicated in the maintenance procedures This resulted in a damaged pylon that was undetected for several flights • During the final takeoff, the pylon failed and the wing was ripped off during takeoff causing the crash Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 133 11. Contractor management The purpose of contractor management is to ensure that contract workers work according to safe work practices and that they don’t increase the operational risk of the facility 134 Specialized skills Maintenance and Repairs Why are contractors used? Construction Equipment Installation Janitorial Work Grounds keeping Many other reasons [3] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 135 Selection Process of Contracting Acquisition Use (& Training) Monitoring [3] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 136 Prequalify accredited firms Contractor Management System Introduction Safety record Strong safety culture Employee turnover rate Previous performance Encourage near-miss reporting among contractors. They are the least likely to do so and most likely to get hurt on the job [5] Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 137 The safety valve which was removed earlier, was removed by a contractor that had been hired to inspect/ test it. Piper Alpha Continued [6] Introduction The contractor had not been trained properly in the safe work practices needed for the task. The incident investigation also determined that the inadequate emergency response training given to contractors on the rig contributed to the high loss of life Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 138 12. Training and performance review Training is required to ensure that workers preform a task to a minimum standard, to maintain their proficiency, or to upgrade their skills. Performance reviews determine when these actions are required. 139 Practical instruction in job tasks or methods [3] Enable workers to meet minimum performance standards What is training? Introduction Performed before the worker is allowed to perform the task on their own Followed by performance assurance to confirm that the worker is performing the tasks correctly and that they posses the knowledge, skills, and abilities (KSAs) required for their position Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 140 Start by identifying the KSAs you are trying to develop [3] Developing new training Identify or hire qualified personnel to develop the materials. Procure training materials Develop training program/ course Develop ways to assess the KSAs post-training Validate the training by getting feedback from workers that are currently considered qualified Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 141 Other Elements Job or Task Analysis Job Requirements Gap Analysis New Regulations Incident Investigation Develop Training Program/ Course Training Commitment to PSM Hazard & Risk Assessment Organizational Change Auditing Assess KSAs Inadequate Learning Ability Adequate Learning Ability, periodic refresher training Introduction Management Review Reassign Worker Adapted from [3] Risk Management Enhancing PSM 142 13. Management of change This element proscribes a system for dealing with all types of modification at a facility from chemical supplier changes, facility changes, to personnel changes 143 Management of change (MOC) is critical for preventing changes from increasing the facilities risk of a loss of containment event One of the most important elements Introduction MOC also helps a facility remain in compliance with government regulations, the Responsible Care initiative, and helps maintain other quality initiative like ISO 9000 [7,8] MOC interacts with almost every other element in the risk management area and also the knowledge management element in the hazard assessment section Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 144 A change request is made [7, 8] Qualified independent personnel (i.e. not the requestor) review the request to identify any additional hazards Example process The responsible party either reject or approves the request based on the review If it is approved it can be implemented Prior to implementation the relevant operating procedures or process safety documentation is updated and the potentially affected personnel are informed Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 145 Process Life Cycle Process Development Construction Detailed Design Operating lifetime Extended Shutdowns Decommissioning Startup Many changes will occur throughout the lifecycle of a process facility. The general stages are shown above. [3, 7, 8] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 146 Sometimes emergency changes are necessary. [7, 8] Change must be implemented to prevent an environmental release Correct a deficiency that an immediate threat to the safety of workers The facility must be prepared for an external threat (for example a tidal wave or flood) Emergency Changes Therefore it is useful to have an expedited system. However to prevent unessential use of the system, it should be a requirement to complete the full request for change process as soon as possible afterward. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 147 14. Operational readiness This element covers processes for conducting pre-startup reviews of new processes or processes that were temporarily out of service 148 Processes should be shutdown in a way to confirm they are safe to restart later [3] Duration of shutdown should be a factor in the safety verification Readiness Consider any modifications that we necessary for shutting down the process Likelihood of having an accident is highest during process transitions such as shutdowns and startups A readiness record makes it easy to audit a process later and determine potential issues Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 149 Verify current condition with equipment or design specifications [3] Ensure all process procedures are in place Prior to startup (old & new processes) Operating procedures Safe work procedures Emergency procedures Maintenance procedures Ensure training is completed by operators which may affect the process Confirm the process is safe to operate Inspections Cleanliness Isolation from potential hazards, etc. Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 150 Verify [3] : Equipment readiness (meets design specs) Process control systems Emergency shutdown systems Cleaning processes have been complete (if applicable) Equipment lineup is validated Procedures are in place Emergency response equipment is in place Training is up to date for all operators that may affect the process Readiness Review Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 151 Have undergone full management of change request & approval process [3] New Processes Introduction All documentation has been updated PHA, where necessary, has been completed All equipment or safeguards have been installed Conduct pre-startup review prior to starting the process Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 152 15. Conduct of operations This element focuses on operational discipline. This element is extremely important in a field which is dependent on operators performing their tasks correctly every time. 153 Workers are expected to perform with [3]: Tied to Organizational Culture Alertness Due thought Full knowledge Sound judgement Sense of accountability A workers ability to perform their tasks perfectly repeatedly is dependent on the culture of the organizations Mistakes cannot be tolerated in an environment where small deviations could lead to catastrophic results Formal operational activities are increasingly required for consistent performance in complex systems Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 154 Reliable and consistent operations will also benefit product quality and productivity Accountability Introduction The conduct discipline culture should acknowledge that humans do err. However, it is due to this fact that there is a need to detect these errors and also develop safeguarding systems to prevent them from becoming an accident [3] Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 155 Applies to all workers (management, contractors, operators, engineers, etc.) [3] Often tied close to human resources personnel: Conduct Consequences Fitness of duty assessment Disciplinary actions Salary & bonuses Retention decisions Authority, accountability and work performance indicators should be defined May be coordinated with other element outputs Equipment status for asset integrity Near miss reports for incidents element Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 156 16. Emergency management The emergency management element involves planning for emergencies, practicing them, training employees, contractors and local authorities, as well as communicating with local stakeholders. 157 Protect people onsite and offsite including emergency responders [3] Planning & training Drills Objectives Communicate with stakeholders before an incident Planning & coordination Communicate with the media in the event of a serious incident In conjunction with the stakeholder communication element (element # 5) Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 158 Planning Create emergency procedures such as shutdown, isolation of hazardous materials [3] Create emergency evacuation plans Assess the need for emergency management equipment on site such as: Protecting people Blast walls Fire fighting equipment Plant alarms, etc. Training Train all staff and contractors on the developed procedures and facility evacuation plan Drills Periodically test the readiness of the operators and contractors to safety shutdown and evacuate the facility Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 159 Planning How much a facility will want to depend on municipal emergency responders [3] Preventative vs. Mitigative safeguards Coordination with Municipal Crews Regain control with preventative safeguards to prevent incident Reduce impact of incident with mitigative safeguards Communication Make important information available to municipal crews to protect their safety if an incident occurs (flammables on site, toxic fumes, etc.) Establish a system for ensuring a quick response in the event of an incident Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 160 Emergency management will involve many people from all levels of the organization [3] Immediate actions will be taken by operators: Shutdown the process Isolate hazardous materials Scope Further actions will be coordinated by an incident commander Coordination of specialist teams such as HAZMAT or Fire fighters Order evacuation This person should have experience in emergency decision making Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 161 In the event of an incident Introduction An effective emergency management system will do the following things in the event of a loss of containment incident [3]: Save lives Protect property & the environment Reassure stakeholders that the facility is properly managed and should be allowed to continue operating Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 162 Required by law: Canadian Environmental Protection Act (CEPA) Emergency Management Systems (EMS) Good business Sense: Damage to reputation Customers Employees Community Cleanup costs Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 163 Loss of life may not have been so high if more effective emergency management was present [3]: All personnel authorized to order evacuation were killed in the first blast. Piper Alpha Continued This was due to the fact that the control room where they were located did not contain any blast walls. Poor emergency management design Personnel with authorization to evacuate the facility should not be located together The workers who did not evacuate and were sheltered in the galley were all killed Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 164 Operators were not aware of any procedures to shutdown the process or isolate the hazardous materials [3] Operators did not believe they had the authority to shut down the process even though they could see the rig was on fire This was the direct cause of the second explosion This was due to a lack of emergency procedures Piper Alpha Introduction Evacuation routes were blocked by enormous flames (helicopters) Lack of coordination with government emergency crews Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 165 [1] Trevor Kletz. Plant design for safety: a user friendly approach. Hemisphere Publishing Corporation: New York, 1991. [2] Trevor Kletz. Process Plants: A Handbook for Inherently Safer Design. CRC, 1998. [3] Center for Chemical Process Safety. Guidelines for Risk Based Process Safety. New Jersey : Jon Wiley & Sons, 2011. References [4] National Transportation Safety Board. Aircraft accident report: American Airlines, Inc. DC-10-10, N110AA. Chicago O'Hare International Airport Chicago, Illinois, May 25, 1979. Report 20594, 1986. [5] Center for Chemical Process Safety. Guidelines for Management of Change. New Jersey : Jon Wiley & Sons, 2008. [6] Oil & Gas UK. Piper Alpha: Lessons Learnt, 2008. [7] Chitram Lutchman, Rohanie Maharaj, & Waddah Ghanem. Safety Management: A comphrensive approach to developing a sustainable system. CRC Press: Florida, 2012. [8] Center for Chemical Process Safety. Guidelines for Management of Change. New Jersey : Jon Wiley & Sons, 2008. 166 Enhancing PSM Incident Investigation Measurement and Metrics Auditing Management Review and Continuous Improvement Implementation The most effective PSM systems use new information as it becomes available over the lifetime of the process to continuously improve the PSM system [1] Continuous improvement Enhancing PSM is based on learning from experience This is typically done through: Investigating incidents or near misses that occur and addressing their root causes Apply lessons learned from other similar facilities Measuring performance Auditing the PSM system Performing management reviews 168 17. Incident Investigation As it sounds, this element is about investigating any incidents or near misses to determine the root cause (if possible) and applying this information to improve the PSM system 169 Formal accident reporting, tracking, and investigation system [1] Process Analyzing incident trending Learn from experience – apply newly acquired information if appropriate Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 170 This system is not for blaming employees and results should not be treated as such [1] It should be approached as a mechanism for addressing the underlying system procedures or process cause Organization Culture Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 171 18. Measurement & Metrics This element focuses on measuring and assessing the actual performance of a process and not the intended performance which may become misleading over time. 172 Metrics are indicators of system performance [2] Metrics Incidents frequency is not effective indicators for proactive process improvement It is often used for reactive process improvement, however, proactive prevention should be best practice Types of measurements and frequency of updating indicators is facility and process specific Depends on cost, local needs, the type of process, risk level, operational dynamics, commitment to process safety Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 173 • Easier to take corrective actions proactively, therefore use leading indicators [2] • We call these Key Performance Indicators (KPIs) KPIs There may be some mandatory requirements for KPIs for a particular process or piece of equipment and this should be taken into account. • This element can often be combined with other business metrics such as efficiency, cost analysis, and productivity Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 174 Leading Input measurements which are typically hard to measure but easy to influence. This type of improvement is pro-active [1] Leading & Lagging Indicators Measures the barrier’s strength and maintains it to prevent incidents in the Swiss Cheese Model of PSM failure Lagging Output measurements that are easy to measure but difficult to improve. This type of improvement is reactive Measures the protective barrier defects and the events and consequences in the Swiss Cheese Model of PSM failure Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 175 Indicators Which is leading/lagging [2]? Weighing yourself on a scale Example – Losing Weight Easy to measure Difficult to take corrective action Counting your consumed calories and your expended calories Difficult to measure Easy to take corrective action Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 176 • Long term documentation is dependent on [2]: • Process risk • KPI measurement Regulatory requirements Documenting & Reporting Introduction Often, government or professional associations (such as Responsible Care) will require the reporting of some KPIs This allows them to develop new metrics or recommendations for all facilities in order to improve the safety of whole industries Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 177 19. Auditing This element is critical in assessing the effectiveness of the PSM system. It should identify weaknesses in the design or implementation, and use this information to correct them. 178 Independent Systematic Comparison of current process to Standards of Care Guidelines which include standards, regulatory requirement and other external rules Internal self-imposed requirements What is an Audit? Auditing is most often used during the operating phase of a facility [1] Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 179 How often audits are conducted will depend on several factors [1]: Process inherent risk Phase process life cycle Past experience Frequency Maturity of the PSM system Maturity of organizational culture Facility, corporate, or regulatory requirements Regardless, some audits should be conducted on a regularly scheduled basis such as once a year Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 180 Team based activity [1] However, requires access to operators and experts Team should be lead by competent personnel Element by element (typically) Who & How? Scope Directed primarily by documented protocols Physical Scope – What element or units are being audited? Analytical Scope – What are the auditing criteria? Temporal Scope – What time period are you auditing? E.g. April 1, 2013 - March 30, 2013 Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 181 Audits are not useful on their own [1] Findings must be used to improve PSM Implementing Audit Findings Introduction Commitment to PSM Adopt as proposed Adopt in principle (the recommendation will be implemented in an equivalent manner) Reject based on the assertion that the recommendation was made in error (Because of an error in facts or in judgement) Reject due to a change which has rendered the recommendation inapplicable. Hazard & Risk Assessment Risk Management Enhancing PSM 182 20. Management Review and Continuous Improvement This element focuses on the routine review of management systems for effectiveness and ability to produce the desired results 183 What is a management review? Like an audit, but less formal, more frequent, and the reviewers are generally in-house employees Breakdowns in management systems are harder to detect and slower to be noticed For example: The training coordinator unexpectedly leaves The trainers continue to train people and the element seems intact A management review revels that some workers or contractors are overdue for training At that point it could be too late… Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 184 Hot work Explosion, Delware, 2001 Catwalk above sulphuric acid tank needed welding repair. The sulphuric acid tank below had holes and was in a poor state of repair [1,3] 1 contractor killed and 8 others injured as a result of the explosion Large volume of sulphuric acid was released into the environment Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 185 Management Review Hazards were not assessed correctly since the tank was changed from normal acid service to spent acid service (corrosivity & flammability hazards changed) [1] Root Cause Sulphuric acid tanks were not maintained properly and requests for maintenance were always ignored or deferred Previous requests for hot work were denied due to toxic and sufficient flammable gas concentrations The hot work permit did not specify atmospheric monitoring despite previous permits being denied for this reason Introduction Commitment to PSM Hazard & Risk Assessment Risk Management Enhancing PSM 186 Remember –The elements work together! [1,4,5,6] 187 [1] Center for Chemical Process Safety. Guidelines for Risk Based Process Safety. New Jersey : Jon Wiley & Sons, 2011 [2] Karel van der Poel. Lagging and leading indicators. http://kpilibrary.com/topics/lagging-and-leadingindicators Accessed Nov 9, 2013. References [3] U.S. Chemical Safety and Hazard Investigation Board. INVESTIGATION REPORT. REPORT NO. PB2002108210. http://www.csb.gov/assets/1/19/Motiva_Final_Report .pdf Accessed Nov 9, 2013. [4] Trevor Kletz. Plant Design for Safety: a user friendly approach. Hemisphere Publishing Corporation, 1991 [5] Canadian Society for Chemical Engineering. Process Safety Management Guide. Ottawa : Canadian Society for Chemical Engineering, 2012. [6]. Energy Institute. High Level Framework for Process Safety Management. London : Energy Institute, 2010. 188